U. S. DEPARTMENT OF COMMERCE

NATIONAL INSTITUTE OF STANDARDS AND TECHNOLOGY100 BUREAU DRIVE, STOP 2600GAITHERSBURG, MD 20899-2600OFFICIAL BUSINESSPENALTY FOR PRIVATE USE, $300

FOURTH CLASS

POSTAGE & FEES PAID

NIST

PERMIT NUMBER G195
Kathryn M. Dresser

National Institute of Standards and Technology 

Weights and Measures Division

Gaithersburg, MD 20899-2600

U.S. Department of Commerce

Carlos M. Gutierrez, Secretary

Technology Administration

Michelle O’Neill, Acting Under Secretary

of Commerce for Technology

National Institute of

Standards and Technology

William A. Jeffrey, Director

NIST SP 1020-3

December 2005

Consumer Package

Labeling Guide:

Selling by Count
Certain commercial entities, equipment, or materials may be 

identified in this document in order to describe an experimental 

procedure or concept adequately. Such identification is 

not intended to imply recommendation or endorsement by the 

National Institute of Standards and Technology, nor is it 

intended to imply that the entities, materials, or equipment 

are necessarily the best available for the purpose.

National Institute of Standards and Technology Special Publication 1020-3

Natl. Inst. Stand. Technol. Spec. Publ. 1020-3, 16 pages (December 2005)

Available through NIST Weights and Measures Division

100 Bureau Drive STOP 2600

Gaithersburg, MD 20899-2600

Phone: (301) 975-4004 Fax: (301) 926-0647

Internet: www.nist.gov/owm 
1

Introduction

This guide is intended to provide manufacturers, packers, distributors, and

retailers of packaged products with information about the labeling requirements for commodities that are sold by count in the consumer marketplace. The information in this guide is based on the Uniform Packaging and

Labeling Regulation contained in National Institute of Standards and

Technology (NIST) Handbook 1301. NIST develops Handbook 130 in

cooperation with the National Conference on Weights and Measures, an

organization of industry representatives, government officials, and other

interested parties. Handbook 130 is adopted and enforced by many state

and local regulatory agencies.

Declaration of Identity

The identity of the product shall appear on the package label and shall not

be misleading or deceptive. In most cases when the label appears directly

on the package, the identity of the product shall appear on the principal display panel and be generally parallel to the base of the package. The principal display panel is the panel of the package that the manufacturer, packer,

or distributor intends to be displayed at retail. Directions on how to determine the area of the principal display panel are included later in this guide.

The base of the package shall be determined by how the package is designed

to be displayed.

The identity shall be:

z the name specified in, or required by, any federal or state regulation, or 

z the common or usual name, or

z the generic name or other appropriate description, including a statement of function. For example: "cleaning pads" or "napkins."

1"Uniform Laws and Regulations in the area of legal metrology and engine fuel quality."
2

Declaration of Responsibility

The name and address of the manufacturer, packer, or distributor must be

conspicuously displayed on any package that is sold, kept, offered, or

exposed for sale at a location that is different from where it was packed.

The name shall be the actual corporate name or, when not incorporated, the

name under which business is conducted. The address shall include the

street address, city, state2, and ZIP code3. The street address may be omitted, however, if it is listed in a current city or telephone directory.

Unless it would be misleading, the declaration may be the responsible party's

principal place of business instead of the location where the commodity

was manufactured, packed, or distributed. When the responsible party is

not the manufacturer, the declaration shall include the responsible party's

connection with the package, such as "Manufactured for and packed by" or

"Distributed by."

Declaration of Quantity

All declarations of quantity shall permit price and quantity comparisons. In

general, a declaration of quantity may be expressed in terms of count if

such a declaration would be fully informative. However, in most cases declarations of quantity by count are used in combination with declarations of

weight, measure, or length and area. Combination declarations are

explained later in this document.

A declaration of net quantity shall appear on the package label and shall be

accurate exclusive of all packaging materials. When the label appears directly

on the package, the quantity declaration shall appear in the lower 30 % of

the principal display panel and be generally parallel to the base of the package.

2The country name if outside the United States.

3The country mailing code if outside the United States.
3

Units and Symbols

Only the following words and symbols shall be used in conjunction with a

declaration of count:

Capitalization

Abbreviations may appear in both upper and lower case letters.

Use of Punctuation

Periods or other punctuation should not be used after abbreviations.

Use of Spaces

A space should be used between the abbreviation and the number to which

it refers. For example: 6 ct not 6ct; 140 pc not 140pc.

Singular Form

Abbreviations should be written in the singular form. For example, "pc" is

the symbol for both "piece" and "pieces." 

Prohibited Symbols

Incorrect symbols to use in quantity declarations of count include: cnt and

pce.

count ct

each ea

piece pc
4

Words Accompanying a Quantity Declaration

Use of Phrase “Net”

A quantity declaration of count may stand alone and should not include the

term “net quantity” or just the word “net.” For example: 12 pc, 500 ct, or

100 "commodities" (e.g., tablets) are all acceptable.

Qualifying Phrases Prohibited

Words or phrases that qualify the quantity declaration shall not appear on

the package. For example: "approximately," "minimum," "when packed,"

"not less than," and "at least" are prohibited from appearing near the quantity

declaration.

Combination Declarations

When a quantity declaration of count is not fully informative on its own, it

shall be combined with appropriate declarations of weight, measure, or size.

All combination declarations shall be accurate and shall appear on the principal display panel as part of the quantity declaration.

Supplemental Declarations

When appropriate, the required quantity declaration may be supplemented

by one or more additional declarations of weight, measure, count, or size.

All supplemental declarations shall be accurate and shall appear somewhere

other than on the principal display panel.

Packages Containing a Single Unit

Packages containing only a single unit are not required to declare the number of items as "one" provided the statement of identity clearly conveys the

fact that only one unit is contained in the package. However, depending on

the commodity, net quantity statements specifying weight, volume, length,

or area may still be required.
5

Multi-Unit Packages

Any package containing more than one individual package of a commodity shall bear on the outside of the package a declaration of:

· the number of individual units,

· the quantity of each individual unit, and

· the total quantity of the contents of the multi-unit package.

For example, the quantity declaration on a package of 6 bars of soap might

be: 6 Bars; Net Wt 100 g (3.53 oz) ea; Total Net Wt 600 g (1.32 lb).

However, when a multi-unit package that will not enter interstate commerce

contains six or fewer individual units and those units are all fully visible to

the purchaser, such packages need not include a statement of count. For

example: a package containing six disposable pens packaged in clear plastic.

For food products, a multi-unit package is a package containing two or more

individually packaged units of an identical commodity of the same quantity

that are intended to be sold as part of the multi-unit package but are individually labeled in full compliance with this regulation. Open multi-unit

retail food packages that do not obscure the number of units or prevent

examination of the labeling on each of the individual units are not required

to declare the number of individual units or the total quantity of contents

for the multi-unit package as long as each individual unit is labeled in full

compliance with this regulation. For example: multi-unit soft drink bottles

that are attached with plastic rings.

Combination Packages

A combination package is a package that contains two or more individual

units of dissimilar commodities. For example: a basket of cheese, crackers, sausage, and jams.
6

The quantity declaration for a combination package shall contain a declaration of weight, measure, count, size or any combination of these, for each

individual unit. However, the quantity statement of identical units may be

combined. For example, the quantity declaration on a picnic pack that contains utensils, napkins and cups might be: 20 - spoons, 10 - knives, and 

10 - forks; 10 - 25 cm x 25 cm (10 in x 10 in) 2-ply napkins; 10 - 177 mL

(6 fl oz) cups.

Variety Packages

A variety package is a package that contains two or more individual units of

similar, but not identical, commodities. Similar, but not identical, commodities are commodities that are generically the same but differ in weight, measure, appearance, or quality. For example: a package containing 3 cans of

shoe polish; 1 - white, 1 - black, and 1 - brown.

The quantity declaration for a variety package shall contain a declaration of

weight, volume, measure, count, size or any combination of these, for each

individual unit; and a declaration of weight, volume, measure, count size of

any combination of these, for the total package. For example, the quantity

declaration on a variety package of sponges might be: 4 - 15.2 cm x 25.4 cm

x 2.5 cm (6 in x 10 in x 1 in) Sponges; 4 - 10.1 cm x 20.3 cm x 1.9 cm (4 in

x 8 in x 3⁄4 in) Sponges; 4 - 5.7 cm x 10.1 cm x 1.2 cm (2-1/4 in x 4 in x 1⁄2 in)

Sponges; Total: 12 Sponges.

Prominence and Placement

All information required to appear on a consumer package shall be prominently displayed in the English language. When appropriate, information

may also be displayed in additional languages. Any required information

that is hand lettered shall be clear and equal in legibility to printed materials.
7

Principal Display Panel

The area of the principal display panel shall be:

· for rectangular containers, the height times the width (H x W) of the

front of the package, where the front of the package is determined

based on how the package is designed to be displayed;

· for cylindrical or nearly cylindrical containers, 40 % of the height times

the circumference [0.4 x (H x C)] of the container; 20 cm (8 in) 20 cm (8 in)

15 cm (6 in)

30 cm (12 in)
8

· for other shaped containers, 40 % of the total surface area of the container. However, if the container has an obvious principal display panel

(for example, the face of a triangular package for a pen, or the top of a

can of shoe polish) the area shall be calculated from the shape of that

surface.

Color Contrast

The quantity declaration shall be in a color that contrasts conspicuously with

its background. However, the quantity declaration may be blown, formed,

or molded on a glass or plastic surface if no other label information is presented in a contrasting color.

Free Area

The area surrounding the quantity declaration shall be free of printed information:

· above and below by a space equal to at least the height of the declaration

lettering; and

· to the left and right by a space equal to twice the width of the letter "N"

of the declaration lettering type and style. 25 cm (10 in)

30 cm (12 in)
9

Style of Type

The quantity declaration shall be in a style of type or lettering that is bold,

clear, and conspicuous when compared to other type, lettering, or graphics

on the package. However, if all the label information is blown, formed, or

molded on a glass or plastic surface, then the quantity declaration may also

be blown, formed, or molded on the surface.

Proportionality

No number or letter shall be more than three times as high as it is wide.

Minimum Height

The height of any letter or number in the quantity declaration shall be at

least that shown in the Table on the following page. When all lowercase letters are used, it is the lowercase "d," or its equivalent in the print or type,

that shall meet the minimum height requirement. No letter shall be less than

1.6 mm (1/16 in) in height. Other letters and exponents shall be presented in

the same type style, and in proportion to the type size used.
12

Area of Principal 

Display Panel

Note: The type and size requirements specified in this table do not apply to the “e” mark.

Minimum Height of Numbers and Letters

Minimum Height:

Numbers and Letters

Minimum Height:

Label information blown,

formed, or molded on surface of container

4.8 mm (3/16 in)

4.8 mm (3/16 in) 6.4 mm (1/4 in)

12.7 mm (1/2 in)

6.4 mm (1/4 in) 7.9 mm (5/16 in)

14.3 mm (9/16 in)

3.2 mm (1/8 in)

3.2 mm (1/8 in)

1.6 mm (1/16 in)

More than 32 cm2 (5 in2) and less than or equal to 

161 cm2 (25 in2)

More than 161 cm2 (25 in2) and less than or equal to 

645 cm2 (100 in2)

More than 645 cm2 (100 in2) and less than or equal to 

2581 cm2 (140 in2)

More than 2581 cm2 (400 in2)

Less than or equal to 

32 cm2 (5 in2)

10
11

Figure 1: Example of a package labeled to be sold by count

Edwin’s E nvelopes

Security Envelopes with Printed Lining for Privacy

40 Envelopes

10.48 cm x 24.13 cm

 Appears in the lower 30 % of the principal 

display panel

 Is generally parallel to the base of the 

package

 Has an appropriate amount of free space Uses an appropriate style of type Meets minimum height requirements Includes a combination declaration because 

count alone is not fully informative

 Is prominently display Includes the name and address 

of responsible party

 Includes responsible party’s 

connection with the package

 Appears on principal display panel Is generally parallel to the base of 

the package

 Includes a generic name with 

description

Declaration of Quantity:

Declaration of Responsibility:

Declaration of Identity:

Distributed by

Edwin Inc.

454 W. Oak St.

Perplunk, OH

43550

1-800-013-5790
12

Labeling Checklist for Count

Declaration of Identity

 Appears on the principal display panel.

 Is generally parallel to the base of the package.

 Is the name specified in, or required by, federal or state regulation;

the common or usual name; or the generic name or other appropriate description including a statement of function.

Declaration of Responsibility

 Is conspicuously displayed on any package that is sold, kept, offered,

or exposed for sale at a location other than the premises where

it was packed.

 Includes the name and address of the manufacturer, the packer, or

the distributor.

 Uses the actual corporate name or, when not incorporated, the name

under which the business is conducted.

 Includes the city, state (or country), and ZIP code (or mailing code

used in other countries).

 Includes the street address unless this information is listed in a 

current city or telephone directory.

 Uses the address of the responsible party's principal place of business

or the address of the location where the package was manufactured,

packed, or distributed unless such address would be misleading.

 If the responsible party is not the manufacturer, then includes the

party's connection with the package (i.e., "Manufactured for and

packed by," or "Distributed by").
13

Declaration of Quantity

 Appears in the lower 30 % of the principal display panel.

 Appears generally parallel to the base of the package.

 Is prominently displayed in English (multi-lingual information is 

permitted).

 Is in a color that contrasts conspicuously with its background.

 Has an adequate amount of free area around it.

 Appears in a style of type or lettering that is bold, clear, and 

conspicuous.

 Is of a type or lettering that is proportional.

 Is of a type or lettering that meets the minimum height requirements.

 Uses only approved words, symbols or abbreviations for the units.

 Uses SI symbols that are not capitalized.

 Uses abbreviations that are not accompanied by periods or other 

punctuation marks.

 Uses abbreviations in the singular form.

 Uses SI declarations containing only decimal fractions.

 Does not appear in conjunction with an improper qualifying phrase.

 When necessary, is combined with appropriate additional declarations.
14

Contact Information

National Institute of

Standards and Technology

Weights and Measures Division

100 Bureau Drive, M/S 2600

Gaithersburg, MD 20899-2600

Tel: 301-975-4004

Fax: 301-926-0647

E-mail: TheSI@nist.gov

www.nist.gov/metric

U.S. Federal Trade Commission

600 Pennsylvania Ave, NW

Washington, DC 20580

Tel: 202-326-2222

www.ftc.gov

Handbook 130 is available on the NIST Weights and Measures Division website at:

www.nist.gov/owm; click on "Handbook 130, Uniform Laws and Regulations" under

the "Quick List (popular links)" section.

The Fair Packaging and Labeling Act (FPLA) is available 

· on the FDA website at: www.fda.gov/opacom/laws/fplact.htm; or 

· on the FTC website at: www.ftc.gov/ogc/stat3.htm,

click on "Fair Packaging and Labeling Act 

(80 Stat. 1296, 15 U.S.C. §§ 1451-1461)."

A Food Labeling Guide is available on the FDA website at::

www.cfsan.fda.gov/~dms/flg-toc.html

National Conference on

Weights and Measures

15245 Shady Grove Road, Suite 130

Rockville, MD 20850

Tel: 240-632-9454

Fax: 301-990-9771

E-mail: ncwm@mgmtsol.com

www.ncwm.net

U.S. Food and Drug Administration

5600 Fishers Lane

Rockville, MD 20857

Tel: 1-888-463-6332

www.fda.gov